Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 781]
Action Revisions to the Standards for Licensed Child Day Centers
Stage NOIRA
Comment Period Ended on 1/31/2024
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1/25/24  4:54 pm
Commenter: Maria Ferrone, CreativeKids

Review of Proposed Regulations
 

Infant Daily Records:

Requiring us to maintain copies of written Infant Daily Records will be a huge burden, time-consuming, and create issues with unnecessary paperwork and filing of paperwork.  With 16 Infants currently enrolled, maintaining over 700 individual pieces of paper every 60 days will be quite a burden.  We use an electronic app, the ProCare Parent Engagement App, and have not used paper for quite some time.  Our filing cabinets are bursting at the seams and this past year I have had to purchase a shed to store 17 banker boxes of old children's and staff's files.  Please reconsider this regulation.

 Outside Assessment Unnecessary for Special Needs Child:

The parent's wishes and the ASQ Assessment that we currently do on all new children should suffice.  If the child needs to be in a classroom that is designated for a "younger age group" because of developmental needs, that is what is best for the child.

Mixed Age Play Outdoors:

It is greatly beneficial for mixed ages to play together, especially outside.  If the youngest age group sets the ratio and the group size, why would we take this opportunity away?

Topical Ointments & Documentation:

Please, please, please DO NOT require us to document and log in every time we apply sunscreen, diaper creme, and/or eczema cream/topical ointment.  That takes precious time away from the teachers who are already tied up applying the product.  If we have the parent's permission with the directions, it should suffice.  We do not have the time or the manpower to conduct all of these secretarial duties...especially with sunscreen, when we have 25 kids needing sunscreen.  Please reconsider this proposed policy.

Central Registry Findings:

The Criminal Background Checks usually come back within 48 hours, however having to wait on the CPS Report is quite lengthy and places a burden on hiring staff quickly and oboarding them in a timely manner.  Please allow them to be onboarded, while under the supervision of a senior staff member, until their CPS Clearance is received.  They should not be left alone with children but should be able to be counted in the ratio while they are waiting it to return.

Creating Additional Written Policies:

This is so redundant and unnecessary.  If the policy is written in the Standards, that is exactly how it will be followed.  With orientation, mandated training, required yearly training, etc. many of the items requiring a written policy are already covered.  Please do not place this burden on us to simply type something up, that is already stated, just to have more paper!

Parent's Written Notification of Behavior

I strongly disagree that this needs to be written.  While we do complete Incident Reports for documentation, awareness, and tracking purposes, please do not allow all centers to require that.  With the incident report in hand, it is our conversation with these parents that helps the child the most.  These are delicate conversations that need to happen and if you make this a written requirement, I worry that those conversations will be replaced and not happen at all.

Recycled Materials:

Please change the wording and make it CLEAN AND SAFE RECYCLED MATERIALS.  We use the Creative Curriculum.  It is a State-Approved Curriculum and there is an entire unit on Recycling!  It's actually one of the children's favorite!  Please consider allowing us to teach them about recycling by being able to provide those hands-on projects which are so impactful and memorable to them!

Centers must provide Scheduled Opportunities to provide feedback:

It sounds like another thing to track and more needless papers to be kept.  We conduct parent-teacher conferences formally twice a year, more if needed or requested by the parent, but we also speak to our parents once, most twice per day.  Please remove the word "scheduled" from this policy and simply make sure that Parents/Guardians are provided opportunities to provide feedback.

EPI PEN and LEAD TESTING

Please refrain from making this regulatory until the protocol has been set and we have access to the materials needed to follow this policy as it is written.  

Thank you for all the hard work!

 

 

CommentID: 221503